2012 (6) TMI 351

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....ng question of law :   "Whether, on the facts and in the circumstances of the case and in law, the Income-tax Appellate Tribunal was justified in granting deduction in respect of the new unit at Silvassa disregarding the fact that the activities of the assessee do not amount to manufacturing and that the assessee is not entitled to any deduction under section 80-IA in respect of a new unit....

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....olours, oil pastels and water colours. According to the Commissioner (Appeals), the provisions of section 80-IA were applicable only to those undertakings which had commenced commercial production before March 31, 2000. In appeal, the Tribunal observed that the assessee had started manufacturing some new items of the same nature and for the purpose installed some new plant and machinery along with....